Relief for Pakistan underlying tax is available only if the United Kingdom recipient of the dividend is a company controlling, directly or indirectly, 10 per cent of the voting power of the Pakistan company.

Pakistan direct tax on the dividend is restricted as follows

where the recipient is an individual: 20 per cent

where the recipient is a company controlling more than 50 per cent of the voting power of the payer and the payer carried on an `industrial undertaking’ when the agreement came into force: 10 per cent.

Where the industrial undertaking was set up later the control requirement is reduced to 25 per cent of the voting power. `Industrial undertaking’ is defined in Article 10(4)(b).

where the recipient is a company other than those referred to above: 15 per cent.